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States v. Bobby Wolford Trucking & Salvage, Inc.

United States District Court, W.D. Washington

July 9, 2019

UNITED STATES OF AMERICA, Plaintiff,
v.
BOBBY WOLFORD TRUCKING & SALVAGE, INC., and KARL FREDERICK KLOCK PACIFIC BISON, LLC, Defendants.

          Kent E. Hanson U.S. Department of Justice Environmental Defense Section Attorneys for Plaintiff

          Connie Sue Martin, WSBA #26525 SCHWABE, WILLIAMSON & WYATT, P.C. Attorney for Defendant Bobby Wolford Trucking & Salvage, Inc.

          James A. Tupper, Jr. Tupper Mack Wells PLLC Attorney for Defendant Karl Frederick Klock Pacific Bison, LLC

          STIPULATED PROTECTIVE ORDER

          Thomas S. Zilly United States District Judge

         1. PURPOSES AND LIMITATIONS

         Discovery in this action is likely to involve production of confidential, proprietary, or private information for which special protection may be warranted. Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated Protective Order. The parties acknowledge that this agreement is consistent with LCR 26(c). It does not confer blanket protection on all disclosures or responses to discovery; the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles; and it does not presumptively entitle parties to file confidential information under seal.

         2. “CONFIDENTIAL” MATERIAL

         “Confidential” material shall include the following documents and tangible things: (1) federal income tax returns and associated schedules, attachments, statements, and worksheets submitted to the Internal Revenue Service; (2) financial statements (audited and unaudited); balance sheets; income statements; cash flow statements; financial notes; auditor opinions; financial summaries; financial compilations; descriptions of annual revenue, costs and expenses; descriptions of liabilities; and loan applications; and (3) information in the possession, custody or control of the United States Environmental Protection Agency that was designated as “Confidential Business Information” and submitted pursuant to 40 C.F.R. Part 2. Subpart B, prior to the commencement of this action.

         3. SCOPE

         The protections conferred by this agreement cover not only confidential material (as defined above), but also (1) any information copied or extracted from confidential material; (2) all copies, excerpts, summaries, or compilations of confidential material; and (3) any testimony, conversations, or presentations by parties or their counsel that might reveal confidential material.

         However, the protections conferred by this agreement do not cover information that is in the public domain or becomes part of the public domain through trial or otherwise.

         4. ACCESS TO AND USE OF CONFIDENTIAL MATERIAL

         4.1 Basic Principles.

         A receiving party may use confidential material that is disclosed or produced by another party or by a non-party in connection with this case only for prosecuting, defending, or attempting to settle this litigation. Confidential material may be disclosed only to the categories of persons and under the conditions described in this agreement. Confidential material must be stored and maintained by a receiving party at a location and in a secure manner that ensures that access is limited to the persons authorized under this agreement.

         4.2 Disclosure of “CONFIDENTIAL” Information or Items.

         Unless otherwise ordered by the court or permitted in writing by the designating party, a receiving party may disclose any confidential material only to:

(a) the receiving party's counsel of record in this action, as well as employees of counsel to whom it is reasonably necessary to disclose the information for this litigation;
(b) the officers, directors, and employees (including in house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation, unless the parties agree that a particular document or material produced ...

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